BIHAR STATE ROAD DEVELOPMENT CORPORATION LIMITED,PATNA vs. ACIT, COR-2, PATNA

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

section 147 of the Act after recording reasons and obtaining prior approval from the competent authority. Thereafter, a notice u/s 148 of the Act was issued to the assessee on 21.04.2016. In response, the assessee e-filed its return on 03.06.2016 declaring total income of ₹8,00,00,000/-. Thereafter notices

BIHAR STATE ROAD DEVELOPMENT CORPORATION LTD,PATNA vs. ACIT, CIR-2, P)ATNA

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

section 147 of the Act after recording reasons and obtaining prior approval from the competent authority. Thereafter, a notice u/s 148 of the Act was issued to the assessee on 21.04.2016. In response, the assessee e-filed its return on 03.06.2016 declaring total income of ₹8,00,00,000/-. Thereafter notices

BIHAR STATE ROAD DEVELOPMENT CORPN. LTD.,PATNA vs. ACIT, CIRCLE 2, PATNA

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

section 147 of the Act after recording reasons and obtaining prior approval from the competent authority. Thereafter, a notice u/s 148 of the Act was issued to the assessee on 21.04.2016. In response, the assessee e-filed its return on 03.06.2016 declaring total income of ₹8,00,00,000/-. Thereafter notices

BIHAR STATE ROAD DEVELOPMENT CORPN. LTD.,PATNA vs. ACIT, CIRCLE 2, PATNA

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

section 147 of the Act after recording reasons and obtaining prior approval from the competent authority. Thereafter, a notice u/s 148 of the Act was issued to the assessee on 21.04.2016. In response, the assessee e-filed its return on 03.06.2016 declaring total income of ₹8,00,00,000/-. Thereafter notices

PAVAN KUMAR BHAGAT,SAHARSA vs. ITO, WARD-3(4), SAHARSA, SAHARA

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 271AAC, 272A(1)(d) and 271F of the Act. 17. For that the appellant shall place any other point/points at the time of hearing of the appeal.” 3. Brief facts of the case are that the assessee had not filed his return of income for the year under consideration and as per information available with the Assessing Officer (hereinafter

MAHANT PANDEY,ROHTAS vs. NFAC, DELHI

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

147 unless reasons are communicated. In the instant case, the contention of the assessee is that the assessee has complied with the notice under section 148 and the assessing officer has not furnished the reasons recorded for issuance of notice under section 148 despite the request made by the assessee. The Revenue could not place any evidence to controvert

MAHANT PANDEY,ROHTAS vs. NFAC, DELHI

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

147 unless reasons are communicated. In the instant case, the contention of the assessee is that the assessee has complied with the notice under section 148 and the assessing officer has not furnished the reasons recorded for issuance of notice under section 148 despite the request made by the assessee. The Revenue could not place any evidence to controvert

BIJAY KUMAR SARAF,DALDALI BAZAR, MUZAFFARPUR vs. DC/AC CIRCLE 1,MUZFFARPUR, IT-OFFICE, POLICE LINE, SIKANDERPUR MUZZAFFARPUR

In the result, the appeal filed by the assessee is partly allowed

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

section 147 of the Act. The notice issued u/s 147 is beyond jurisdiction. 7. For that the learned commissioner of income tax (Appeals) had failed to appreciate the fact that the appellant has disclosed all material facts, produced books of account, audit report, TDS

HYGIENIC PRODUCTS FOR COMMON CITIZENS,MADHEPURA vs. ITO WARD 3(4), SAHARSA, SAHARSA

In the result, the appeal of the assessee is allowed for statistical\npurposes

TDS statement, in-\nterest received. Hence, AO passed assessment order u/s 147 r.w.s. 144 read\nwith section 144B dated 29.02.2024 by making

ACIT, CENTRAL CIRCLE-3, PATNA vs. BROADSON COMMODITIES PVT LTD, DHANBAD

In the result, both the appeals of Revenue are dismissed, whereas the Cross Objections filed by the assessee are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

TDS, TCS and self- assessment tax. Ground No. 10-General in nature. During the course of appellate proceedings appellant raised additional ground which is as under: - “That on the facts and circumstances of the case, the Assessing officer erred in making an addition of Rs. 5,50,00,000/- on the basis of seized documents found in third party

ACIT, CENTRAL CIRCLE-3, PATNA vs. BROADSON COMMODITIES PVT LTD, DHANBAD

In the result, both the appeals of Revenue are dismissed, whereas the Cross Objections filed by the assessee are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

TDS, TCS and self- assessment tax. Ground No. 10-General in nature. During the course of appellate proceedings appellant raised additional ground which is as under: - “That on the facts and circumstances of the case, the Assessing officer erred in making an addition of Rs. 5,50,00,000/- on the basis of seized documents found in third party

PRERNA AGENCY PVT LTD,KOLKATA vs. INCOME TAX OFFICER, WARD 2(1), PATNA

In the result, the appeal filed by the assessee is allowed

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

section 147 of the Act and therefore at this stage the revenue cannot be permitted to take benefit of the second proviso." 14. Keeping in view the discussion made above and going over the facts of the case and there is no doubt that loan taken by the assessee through account payee cheque had already been repaid for the similar

ITO, WARD-4(1), PATNA vs. HEMANT KUMAR DAS, PATNA

In the result, the appeal of the Revenue is dismissed and the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

147 or revision under section 263. Efforts at the end of the ld. CIT(DR) are that issue be remitted back to the Assessing officer for further investigation because ld. CIT(Appeals) has committed an error in blindly following the finding of the ld. Assessing Officer in a remand proceeding. It is true in a given circumstances, this aspect

BBCPL-RCPL (JV),JAMUI vs. PCIT CENTRAL, PATNA, PATNA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 147. In both the years, the profit on the receipts has been accepted at 6% and 7%. This year, ld. Assessing Officer has estimated the profit at 8% of the gross receipts. Therefore, directly there is no revenue loss. Apart from the above, the ld. Assessing Officer was fully aware that source of receipts and their genuineness

BALKRISHNA BHALOTIA CONSTRUCTION PRIVATE LIMITED,JAMUI vs. PCIT CENTRAL, PATNA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 147. In both the years, the profit on the receipts has been accepted at 6% and 7%. This year, ld. Assessing Officer has estimated the profit at 8% of the gross receipts. Therefore, directly there is no revenue loss. Apart from the above, the ld. Assessing Officer was fully aware that source of receipts and their genuineness

BBCPL-SKPL (JV),JAMUI vs. PCIT CENTRAL, PATNA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad

Section 147. In both the years, the profit on the receipts has been accepted at 6% and 7%. This year, ld. Assessing Officer has estimated the profit at 8% of the gross receipts. Therefore, directly there is no revenue loss. Apart from the above, the ld. Assessing Officer was fully aware that source of receipts and their genuineness

DEEPAK SHRAWAN BUDHIA,MUMBAI vs. PR. COMMISSIONER OF I.T., PATNA-1, PATNA

In the result, appeal of the assessee is dismissed

Bench: SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER SHRI SONJOY SARMA (Judicial Member)

TDS on freight as per provisions of section 40(a)(ia) of the 1. T. Act, 1961 was passed without considering all provisions of Sec 147

ANIL KUMAR,NALANDA vs. ITO, WARD- 2 (3), BIHARSHARIF

In the result, the appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Dr. Manish Boradi.T.A. No. 361/Pat/2023 Assessment Year: 2014-15 Anil Kumar National Faceless Assessment Centre M/S Raj Trading Company, Nfac, Delhi Harnaut, Nalanda, Patna-803110 Vs Bihar [Pan : Azopc268H] अपीलार्थी/ (Appellant) प्रत्‍यर्थी/ (Respondent)

147 read with section 144B of the Income-tax Act, 1961 (the Act) dated 22nd August, 2021, framed by Income Tax officer, NFAC. 2. The registry has informed that the appeal is time barred by 46 days. The assessee had filed an application for condonation of delay. Perusal of the same indicates that the assessee did not came to know